24 July 2026

Tax Reliefs, part 6: Robotization Tax Relief

In the next article in our Tax Relief Series, we present an overview of the Robotization Tax Relief. The relief for innovative employees is a relatively new instrument within the Polish income tax system. It was introduced in 2022 as part of the legislative package commonly referred to as the Polish Deal (Polski Ład).

The Robotization Tax Relief is another incentive designed to promote innovation. Its primary objective is to increase the level of robotization and automation within Polish businesses by encouraging investment in industrial robots. Unlike several other tax incentives introduced under the Polish Deal, the Robotization Tax Relief is available only for the period 2022–2026. Consequently, 2026 is the final year in which taxpayers may make qualifying investments in robotization and automation in order to benefit from the additional tax incentives.

At the same time, the Ministry of Finance has announced that it is not currently undertaking any legislative work to extend the duration of the relief. Any future amendments and the direction of potential changes will depend on analyses and conclusions drawn from the operation of the existing regime. Nevertheless, an extension of the relief has not been ruled out, as this would allow for a more comprehensive assessment of this pilot programme.

How Does the Robotization Tax Relief Work?

The Robotization Tax Relief is a tax incentive that allows taxpayers to claim an additional deduction equal to 50% of eligible robotization expenses. In practice, this means that, in addition to treating qualifying expenditures as tax-deductible costs through standard tax depreciation, taxpayers may deduct a further 50% of the eligible costs associated with those assets.

The additional deduction is claimed in the annual tax return by reducing the taxpayer’s taxable income.

The legislation provides a catalogue of eligible expenditures that may qualify for the relief, including:

• the purchase or lease of brand-new industrial robots;
• the acquisition of machinery and peripheral equipment functionally connected with industrial robots (including rail systems, positioners, rotary tables, setters, and cleaning stations);
• the purchase of machinery, equipment, and other items functionally connected with industrial robots that improve workplace ergonomics and occupational safety (such as sensors, controllers, and relays);
• the acquisition of machinery, equipment, or systems used for the remote management, diagnostics, monitoring, or servicing of industrial robots (including sensors and cameras);
• the purchase of human-machine interface (HMI) equipment;
• employee training related to the operation of newly acquired industrial robots; and
• software for industrial robots and related equipment.

The legislation also introduces statutory definitions of an industrial robot and peripheral equipment for industrial robots.

Industrial Robots and Peripheral Equipment

Under the statutory definition, an industrial robot is a brand-new machine that possesses all of the following characteristics:

• it is automatically controlled;
• it is programmable;
• it is multifunctional;
• it is stationary or mobile;
• it has at least three degrees of freedom;
• it possesses manipulative or locomotion capabilities;
• it is designed for industrial applications;
• it exchanges data digitally with control, diagnostic, or monitoring systems;
• it is connected to ICT systems;
• it is monitored by sensors, cameras, or similar devices; and
• it is integrated with other machinery within the taxpayer’s production process.

Accordingly, a machine must satisfy all of the above conditions in order to qualify as an industrial robot.

One of the key interpretative issues concerns the requirement that the robot be intended “for industrial applications.” Divergent positions have emerged between the Director of the National Revenue Information (KIS) and the administrative courts.

The Director of the KIS consistently maintains that, in order to qualify for the relief, a machine must participate directly in the manufacturing process. Consequently, equipment used solely for warehousing or distribution functions does not qualify. This interpretation is based primarily on dictionary definitions of the terms “industry” and “production.”

The administrative courts have adopted a broader interpretation. In their view, manufacturing processes encompass not only the direct production of goods but also other stages that are inseparably connected with production. As a result, the courts have generally taken a taxpayer-friendly approach, enabling a broader range of businesses to benefit from the relief.

With respect to machinery and peripheral equipment functionally connected with industrial robots, the legislation does not provide an exhaustive definition. Instead, it sets out a non-exclusive list of examples, including:

• linear units increasing the robot’s range of motion;
• single- and multi-axis positioners;
• rail systems;
• pillar-mounted booms;
• rotary tables;
• setters;
• cleaning stations;
• automatic charging stations;
• loading and unloading stations;
• collision couplings; and
• end effectors enabling interaction with the surrounding environment, including tools used for:
  • coating, painting, varnishing, dispensing, gluing, sealing, welding, cutting (including laser cutting), bending, deburring, shot blasting, sandblasting, grinding, polishing, cleaning, brushing, surface finishing, bricklaying, die casting, soldering, spot welding, clinching, drilling, handling (including manipulation, transfer, assembly, loading, unloading, packaging, nailing, palletizing and depalletizing), sorting, mixing, testing, and measurement; and
  • operating machinery such as milling machines, injection moulding machines, bending machines, robodrills, drilling machines, lathes, spindles, cutting machines, rolling mills, grinders, boring machines, drawing machines, printers, presses, and metal spinning machines.

The use of the phrase “in particular” confirms that this list is illustrative rather than exhaustive. Accordingly, additional machinery and equipment functionally connected with industrial robots may also qualify for the relief, provided the statutory requirements are met.

Claiming the Relief

The Robotization Tax Relief allows taxpayers to deduct 50% of eligible tax-deductible expenses incurred on robotization. However, it is important to clarify what constitutes such expenses.

Industrial robots and machinery acquired by taxpayers are generally recognised as fixed assets for both accounting and tax purposes. Consequently, their cost is recovered through tax depreciation. This has given rise to uncertainty as to whether the additional deduction should be calculated based on 50% of the annual depreciation charges recognised in a given tax year.

According to the Director of the KIS, as expressed in numerous individual tax rulings, only the tax depreciation charges recognised during the relevant tax year qualify for the additional deduction. Consequently, the tax benefit relating to the acquisition of an industrial robot must be spread over the asset’s depreciation period.

The administrative courts have taken a different approach. Several Provincial Administrative Courts have ruled that taxpayers should be entitled to calculate the additional deduction based on 50% of the net purchase price of the industrial robot, as shown on the purchase invoice. This interpretation is considerably more favourable than that adopted by the tax authorities and may provide a stronger incentive for businesses to invest in robotization and automation.

The Robotization Tax Relief is claimed in the taxpayer’s annual income tax return by completing the relevant attachment (CIT/O or PIT/O) and indicating the amount of the deduction. Taxpayers must also submit information regarding eligible robotization expenditures using the appropriate forms (CIT-RB or PIT-RB).

It should also be remembered that, despite the pilot nature of the Robotization Tax Relief and its formal application to the years 2022–2026, taxpayers may still claim the relief retrospectively, provided that a thorough review confirms that the relevant expenditures satisfy the statutory eligibility requirements.